SAFETY ALERT

Safety Alert No. 438 Contact: bseepublicaffairs@bsee.gov

April 18, 2022 Phone: (800) 200-4853

Barricades and Fall Protection Will Help Prevent

Injuries Even Without Open Holes Visible

(Left Top) Photo of unbarricaded deteriorated metal grating

deck and (left bottom) close up of grating that parted. (Above)
Photo of replaced corroded grating on the plus 10 deck where
man overboard incident occurred.

In the Calendar Year 2021, numerous grating incidents were reported to BSEE, with
individuals partially or entirely falling through the grating. These incidents were primarily
associated with repairing or replacing deteriorated grating. Incident commonalities included
personnel not donning falling protection equipment and lack of barricades around
questionable grating areas. Due to the increase in occurrences in the Gulf of Mexico, BSEE
concentrated on the relevant hazards to identify improvement opportunities. Below are the
descriptions of sampled events for background:

Incident #1: A construction contractor fell into the water while replacing corroded grating on
the plus 10 deck. The individual self-rescued by swimming to the nearby boat landing and
climbing out of the water. Before falling into the water, the individual exited the barricaded
area, removed his fall protection, re-entered the barricaded area without fall protection, and
began taking measurements before the suspected grating gave way. Although the
construction crew reported the incident to their immediate supervisor, the “man overboard”
incident was not immediately reported to the facility’s person in charge. Photographs of the
deteriorated grating and open hole were not captured.

Incident #2: A construction crew member’s foot fell through grating when walking across an
area known to have deteriorated and hazardous grating. The hazardous and deteriorated
grating was not barricaded or flagged off (see left photos above), and the individual was not
wearing any fall arrest equipment. The individual was able to grab a nearby skid panel
during the fall and prevented himself from completely falling through the grating.

Therefore, BSEE recommends that operators and contractors consider the following:

• Ensuring all personnel inspect fall protection equipment before donning it and
starting work in a barricaded area and/or an area with signage indicating the
presence of holes or deteriorated grated and handrails.

• Ensuring that personnel write up a Job Safety Analysis (JSA) (or similar job safety
work plan) that covers the fall protection equipment, barricading the area in
question, and breaking down how to safely work when repairing/replacing
deteriorated or missing grating and handrails.

• Installing barricades or flagging areas around hazardous, deteriorated, or

questionable grating even if there are no open holes present at the time.
• Having personnel wear proper fall arrest equipment when working in or near any
area known to have or suspected to have degraded grating even if there aren’t any
open holes.
• Having personnel stay vigilant of surroundings and hazards while replacing grating
or over areas where grating is suspected of needing to be changed out or repaired.
• Ensuring all members onboard are aware of possible hazardous areas when
arriving to the facility.
• Adding signage where barricades are present noting why barricades are there
and emphasizing any required fall protection.
• Implementing stop work authority if there are any actions that are deemed unsafe
or new hazards are found.
• Reporting all incidents to the Operator’s Representative onboard and reporting
those incidents to BSEE as outlined in CFR 250.188.
• Reviewing Safety Alert 427 for recommendations regarding physical changes to
grating and how it can affect its integrity.

A Safety Alert is a tool used by BSEE to inform the offshore oil and gas industry of
the circumstances surrounding a potential safety issue. It also contains
recommendations that could assist avoiding potential incidents on the Outer
Continental Shelf.

Category: Grating/Open Holes